Belgium Proposes Mandatory B2B E-Reporting from 2028 with Five-Day Reporting Deadline

Belgium has submitted a draft law introducing mandatory electronic reporting of B2B invoice data from January 1, 2028. The proposal requires suppliers and customers to report transaction data through Peppol within a maximum of five calendar days, replacing the annual customer listing for affected businesses.

Belgium has submitted a draft law to the Chamber of Representatives introducing mandatory Electronic Reporting (E-Reporting) of invoice data from January 1, 2028. The government submitted the proposal on October 27, 2026, under parliamentary document DOC 56 1846/001.

The proposed legislation would amend Article 53quinquies of the Belgian VAT Code, introducing transaction-level reporting to the Belgian Federal Public Service Finance (FPS Finance). The measure would build on the mandatory structured B2B E-Invoicing requirements that entered into force on January 1, 2026.

Under the proposed system, invoice data would be reported electronically through the Peppol network, with a maximum reporting period of five calendar days. The legislation remains a draft and has not yet entered into force.

What would the new E-Reporting system require?

The proposal introduces a two-sided reporting model, meaning that both suppliers and customers would be responsible for submitting data relating to qualifying transactions.

Currently, Belgian businesses subject to mandatory B2B E-Invoicing must exchange structured E-Invoices with their business customers. However, these invoices are not automatically reported to the Belgian tax administration under the existing national framework.

From 2028, the proposed system would add an electronic reporting obligation, allowing FPS Finance to receive transaction information shortly after an invoice is issued or received.

Reporting would take place through the Peppol network rather than through a separate tax administration application.

The proposal also establishes a maximum reporting deadline of five calendar days, except in specified cases of force majeure. The exact deadlines, reporting procedures, and technical requirements would be determined by a subsequent Royal Decree.

Importantly, the proposal limits reportable information to data already required on structured E-Invoices or equivalent documents under Belgian VAT legislation. The final selection of mandatory data fields has not yet been established. Corrective documents, including Credit Notes, would also fall within the reporting framework.

Who would be affected by the proposed requirements?

The new system would primarily apply to Belgian VAT-registered businesses conducting domestic B2B transactions covered by the structured E-Invoicing obligation.

This includes retailers that sell goods or services to business customers and issue B2B invoices, as well as retail businesses receiving invoices from their suppliers.

Certain transactions involving foreign businesses holding a Belgian VAT number would also fall within the proposed reporting framework. For example, a Belgian retailer making a qualifying domestic sale to a foreign business registered for VAT in Belgium could be required to report that transaction, even where mandatory structured E-Invoicing does not apply.

Specific provisions also address transactions involving VAT groups and certain special VAT arrangements.

However, the proposal does not introduce general transaction-by-transaction reporting for B2C sales. Ordinary sales to consumers would not automatically become reportable under this framework.

Intra-Community transactions are also outside the main domestic reporting model. Separate EU reporting requirements are planned under VAT in the Digital Age (ViDA) from July 1, 2030.

What happens to the annual customer listing?

The proposed legislation would replace the existing annual listing of VAT-registered customers with transaction-level electronic reporting for businesses subject to the new obligation.

However, businesses would still need to submit the annual customer listing covering transactions performed during 2027, with the existing deadline of March 31, 2028.

A transitional arrangement would also apply to businesses not established in Belgium but holding a Belgian VAT number. These businesses would generally continue submitting annual customer listings for transactions performed between January 1, 2028, and June 30, 2030, unless they opt into the electronic reporting system under the applicable conditions.

Periodic VAT returns would remain mandatory because E-Reporting would not contain all information required to calculate VAT liabilities and deductions.

Impact on retailers and POS providers

The proposal would affect retail businesses conducting B2B sales through their Point-of-Sale (POS) Systems, particularly where invoicing is handled through separate ERP or accounting software.

Retailers may need to ensure that their systems can distinguish B2B transactions subject to reporting from ordinary B2C sales, identify the correct customer VAT information, and transfer the required data to the system responsible for E-Reporting.

For POS software providers, the practical requirements would depend on whether their solutions issue E-Invoices directly or transfer transaction data to an external invoicing system.

Businesses would also need to consider how Credit Notes, invoice corrections, and incoming supplier invoices are handled. The proposed two-sided reporting model means that receiving an E-Invoice could trigger reporting responsibilities independently of the original sale.

The measure does not introduce new GKS 2.0 requirements or replace the existing fiscalization obligations applicable to qualifying hospitality businesses.

From our perspective, the main challenge would be determining where the E-Reporting obligation should be handled within the retailer's existing software architecture. A POS System may record the sale, while the ERP system generates the structured E-Invoice and communicates with Peppol. In such cases, retailers and software providers would need to establish which system is responsible for reporting and how transaction corrections are communicated between systems.

Another consideration is the proposed comparison of supplier and customer reporting data. Differences may arise from invoice receipt dates, corrections, or disputed transactions, and should not automatically be treated as non-compliance.

The final implementation rules will therefore be particularly relevant for businesses using multiple systems to manage B2B transactions.

What should the affected businesses do know?

Although the legislation is not yet adopted, retailers and software providers should review their existing B2B invoicing processes and determine whether their solutions could support the proposed reporting model.

Businesses should assess their Peppol connectivity, responsibility for incoming and outgoing invoice reporting, and procedures for corrections and transmission failures.

The final legislation and subsequent Royal Decree should be monitored to confirm the reporting scope, technical specifications, and exact deadlines.

The proposed implementation date is January 1st, 2028. No new E-Reporting obligation applies solely on the basis of this draft law.

The sources for the news include the Draft Law, also, the Peppol e-reporting bill before Parliament from November 3rd 2026 - Source Source

Tara Nedeljković Team Lead of Legal Consultants Linkedin profile